This office has recently completed an audit of the Utility Workers Council Local Union 330
under the Compliance Audit Program (CAP) to determine your organization's compliance
with the provisions of the Labor-Management Reporting and Disclosure Act of 1959
(LMRDA). As discussed during the exit interview with Karen Stalilonis on December 23,
2008, the following problems were disclosed during the CAP. The matters listed below are
not an exhaustive list of all possible problem areas since the audit conducted was limited in
scope.

Recordkeeping Violations

Title II of the LMRDA establishes certain reporting and recordkeeping requirements. Section 206
requires, among other things, that labor organizations maintain adequate records for at least five years
by which each receipt and disbursement of funds, as well as all account balances, can be verified,
explained, and clarified. As a general rule, labor organizations must maintain all records used or
received in the course of union business.

For disbursements, this includes not only original bills, invoices, receipts, vouchers, and applicable
resolutions, but also documentation showing the nature of the union business requiring the
disbursement, the goods or services received, and the identity of the recipient(s) of the goods or
services. In most instances, this documentation requirement can be satisfied with a sufficiently
descriptive expense receipt or invoice. If an expense receipt is not sufficiently descriptive, a union
officer or employee should write a note on it providing the additional information. For money it
receives, the labor organization must keep at least one record showing the date, amount, purpose, and
source of that money. The labor organization must also retain bank records for all accounts.

The audit of the Utility Workers Council Local Union 330 records revealed the following
recordkeeping violations:

1) General Expenses:

The Utility Workers did not retain adequate documentation for reimbursed expenses and credit
card expenses incurred by Officers Weldon, Stalilonis, and Fortier totalin at least $793.94.
For example, a payment for $53.34 made to Karen Stalilonis with check drafted on
12/28/2007 lacked sufficient supporting documentation.
As previously noted above, labor organizations must retain original receipts, bills, and vouchers
for all disbursements. The president and treasurer of your union, who are required to sign your
union's LM report, are responsible for properly maintaining union records.

2) Meal Expenses

The Utility Workers records of meal expenses did not always include written
explanations of union business conducted or the names and titles of the persons
incurring the restaurant charges. For exam le, $132.94 in reimbursed expenses paid to
President Matthew Weldon with check # dl for a meal at the Longhorn restaurant
lacked adequate documentation on the meal receipt to indicate union business.
Union records of meal expenses must include written explanations of the union business
conducted and the full names and titles of all persons who incurred the restaurant charges.
Also, the records retained must identify the names of the restaurants where the officers or
employees incurred meal expenses.

3) Lack of Salary Authorization

The Utility Workers Union did not maintain records to verify that the salaries reported in Item
24 (All Officer and Disbursements to Officers) of the LM-3 was the authorized amount and
therefore was correctly reported. Specifically, the union failed to provide documentation for
authorization of $150 Christmas bonus checks that were given to officers. The union must keep
.a record, such as meeting minutes, to show the current salary authorization by the entity or
individual in the union with the authority to establish salaries.
Based on your assurance that The Utility Workers Local 330 will retain adequate
documentation in the future, OLMS will take no further enforcement action at this time
regarding the above violations.

Reporting Violations

The audit disclosed a violation of LMRDA Section 201(b), which requires labor organizations to file
annual financial reports accurately disclosing their financial condition and operations. The Labor
Organization Annual Report Form LM-3 filed by the Maintenance and Service Employees Union for
fiscal year ending 06/30/2007, was deficient in the following area:

1) Failure to accurately report officer salary.

Payments made by the union to National Grid on behalf of officers as reimbursement
for union leave payments made by the employer were not included as salary
payments in the LM-3 report under Item 24. The union incorrectly reported these lost
time reimbursement payments totaling $45,584.25 as other disbursements, Item 54.
Instructions for the LM-3 report indicate that disbursements for "lost time" should be
included in column D of Item 24.
I am not requiring that Local 330 file an amended LM report for 2007 to correct the deficient
items, but Local 330 has agreed to properly report the deicient items on all future reports it
files with OLMS.

I want to extend my personal appreciation to for the cooperation and courtesy extended
during this compliance audit. I strongly recommend that you make sure this letter and
the compliance assistance materials provided to you are passed on to future officers. If we
can provide any additional assistance, please do not hesitate to call.